Private Companies owned by Government Institutions

Companies owned by Public Institutions

Any South African company of which all the shares are held by a body exempt in terms of section  10(1)(cA)(i) – i.e. wholly-owned by one or more Government Institutions.


Section 10(1)(cA)(ii)

Section 10(1)(cA)(ii) of the Act provides an exemption from normal tax of-

  • any association, corporation or company contemplated in paragraph (a) of the definition of company in section 1(1);
  • all the shares must be held by any institution, board or body if the operations of such association, corporation or company are ancillary or complementary to the object of such institution, board or body

The reference to paragraph (a) of the definition of a company in section 1(1) of the Act refers to any association, corporation or company (other than a closed corporation) incorporated or deemed to be incorporated by or under any law in force or previously in force in the Republic or in any part thereof, or any body corporate formed or established or deemed to be formed or established by or under any such law.

Entities listed in section 10(1)(cA)(i) and (ii) of the Act have to apply for approval . These entities must also comply with other requirements of the section.

Helpful Resources:

EI1 – Application for Exemption from Income Tax – External Form

Guide for Companies Owned by Public Institutions

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